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U.S. & Canada Privacy Policy - Highlights

Effective Date: 18.09.2023

GBA Holding GmbH (“GBA Holding”) and its affiliates and subsidiaries understand the importance of your privacy. This Privacy Policy (the “Privacy Policy”) applies when you visit our U.S. website at Gba-group.us (the (“GBA Holding US website” or “website”), apply for employment with us, or use our U.S. services (the “services”). Our Privacy Policy describes our collection of information during your interactions with our website and services, and the rights and choices you have regarding your information.

This Privacy Policy is intended for customers in North America only. These online offerings and terms do not serve the European Union ("EU") market. EU users should visit www.gba-group.com.

We have taken technical and organizational measures to ensure that data protection regulations are observed both by us and by our technical partners and service providers. On our homepage, only the personal and business data necessary for our service offer are recorded. All other information is voluntary.

By using our GBA Holding US website and services, you agree with the terms of this Privacy Policy and our Website Terms of Use.

Information We Collect

We collect various types of information and data about our users in connection with the services or products provided through the GBA Holding US website, including:

  • Information we collect directly from you;
  • Information we collect indirectly from you; and
  • Information we obtain from third-party sources.

We also may collect information in ways that we describe to you at the point of collection or otherwise with your consent, please see also the different services mentioned below.

How and Why Information is Used

We use information to:

  • Manage our business;
  • Ensure website functionality;
  • Advertise and promote our products and services;
  • Review employment applications;
  • Communicate with consumers;
  • Conduct research;
  • Protect our business; and
  • Other reasons with your consent or where permitted by law.

Sharing of Information

GBA Holding may share your information:

  • With our service providers and vendors;
  • With our affiliated companies;
  • For a merger, acquisition, change in ownership, or reorganization; and
  • When we are legally permitted or required to do so.

Please see our full Privacy Policy for more information.

GBA Holding GmbH – U.S. & Canada Privacy Policy

Effective Date:

Table of Contents

1. Information Collection

GBA Holding collects data, including personal information about you. “Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

In the previous twelve months, we have collected various types of information, including:

Data CategoryExamples of Specific DataWhen the Data is Collected
Browsing InformationIP address or anonymized IP addresses, Browsing History, Browser type, Browser settings, Device ID, Operating system, Cookie ID, GBA US Website access dataWe collect browsing information automatically when you visit our website, or through third-party applications, services, and links listed below.
Commercial InformationBusiness address, Business phone number, Business emailWe collect commercial information when you voluntarily provide it to us.
Contact InformationName, Contact details, Home address, Personal email, Phone numbers, Previous residence address, Google account informationWe collect contact information when you provide it to us via phone, your account, email, online form application submission, or through other means.
Social Media DataUsername, Contact Information, Profile ContentWe collect social media data when you interact with our social media accounts through the widgets located on our website

We collect data and personal information from a variety of different sources, including:

  • Website visitors. We collect browsing information automatically from those who visit our website. We collect contact information, commercial information, and social media data from those who provide it voluntarily via contact forms, job applications, email messages, and social media links.
  • Google products. We use Google Marketing Platform, Google Maps, and Google Analytics to advertise, provide map service, and gain information about our consumers. More information about how user data is handled by Google can be found in Google’s privacy policy: policies.google.com/privacy.
  • Customers, vendors, and service providers. We will collect commercial information, contact information, and financial information when you voluntarily apply for become our customer, vendor, or service provider.
  • Cookies and trackers. We use cookies, Cookiebot, and other embedded tracking technology like web beacons which automatically, or with permission, collect users’ browsing information when they use our website. Our website uses the following cookies:
  • Session cookies: We use so-called cookies to recognize multiple use of an offer by the same user (e.g. if you have logged in to determine your login status). When you visit our site again, these cookies provide information to recognize you automatically. The information obtained in this way serves to optimize our offers and to make it easier for you to access our site. When you close the browser or log out, the session cookies are deleted.
  • Persistent cookies: These are automatically deleted after a predetermined period of time which may vary depending on the cookie. You can delete or block the cookies at any time in the security settings of your browser.
  • Third-party cookies: You can configure your browser settings according to your wishes and, for example, refuse to accept third- party cookies or all cookies. However, we would like to point out at this point that you may then not be able to use all functions of this website. Please read more about these cookies in the respective privacy statements of the third-party providers we use.
  • LinkedIn. The LinkedIn Insight Tag is a JavaScript code snippet that we have embedded on our website, which allows us to perform detailed campaign reporting and provides information about website visitors.
  • Algolia Inc. We use the search function of the provider Algolia Inc. on our website to search for and index content, and collect data from Algolia for the purpose of making the information on our website more user friendly.
  • Polyfill. We use the service Polyfill.io of "The Financial Times Ltd." to render our website content in the best possible quality even on older browser versions.

Sensitive Information. GBA Holding does not collect, use, or process personal information which is classified as sensitive information under certain US or foreign legislation, such as information about racial or ethnic origin, data of know children, political opinions, religious or philosophical beliefs, trade union membership, genetic data or biometric data.

2. Information Retention

GBA Holding uses several criteria to determine how long we should keep categories of personal information. We will retain your personal information for the time period reasonably necessary to achieve the business purposes outlined in this Privacy Policy to the extent permitted by applicable law. Please understand that residual copies of the personal information can be stored in locations or formats that make complete erasure extremely difficult. The best way to ensure you control your information is to give us only the personal information that you are completely comfortable sharing with us.

3. Use of Information

How we use collected information. GBA Holding uses data and personal information for a variety of business purposes, as described below. We use the information we obtain about you to:

  • Manage our business. GBA Holding uses data and personal information to maintain user accounts, facilitate usage of the services, and complete necessary tasks to manage our business and provide our services.
  • Support our website. GBA Holding uses data and personal information to enable the website to be delivered to the user’s computer, improve and optimize our website, and to ensure functionality of our website.
  • Advertise. GBA Holding uses data and personal information to display user-based advertisements based on targeted specific interests.
  • Promote. GBA Holding uses data and personal information to promote our products and services, and provide relevant content to our users.
  • Facilitate job applications. GBA Holding uses data and personal information to process and review job applications.
  • Communicate with customers. GBA Holding uses data and personal information to provide customers with information about products, services, or other requested material, and to process, validate, and deliver products and services. We also use data and personal information to communicate important business information, including delivering notices to you about the use of our services.
  • Conduct research and improve our business. GBA Holding uses data and personal information to conduct gain knowledge and information about our website viewers, marketing research, such as questionnaires and surveys, and to analyze and enhance our marketing communications and strategies.
  • Alert customers to offers and promotions. GBA Holding uses data and personal information to alert you to special offers, updated information, and other new products or services from GBA Holding. GBA Holding also uses personal information to manage your participation in our events and other promotions, where you have signed up for such events and promotions.
  • Protect our business. GBA Holding uses data and personal information to protect against fraud, unauthorized transactions, and other liabilities, and secure our services. by identifying potential hackers and unauthorized users.
  • Facilitate other uses. GBA Holding uses data and personal information for other purposes with your consent or where permitted by law, for example to comply with applicable legal requirements, court orders, legal proceedings, document requests, industry standards, and our internal policies.

4. Selling and Sharing of Information

In the past twelve months, GBA Holding has not disclosed information obtained from consumers to certain third parties in exchange for monetary or other consideration.

We do not sell the personal information of individuals we actually know are less than 16 years of age, unless we receive affirmative authorization from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Individuals who opt-in to personal information sales may opt-out of future sales at any time.

We may disclose your data and personal information:

  • When you consent. Out of respect for your privacy, GBA Holding will not disclose your data and personal information to others without your consent, except as specified in this Privacy Policy.
  • With our service providers and vendors. GBA Holding may transfer all or a portion of your data and personal information to our service providers who help us deliver our products and services to you and for the purposes described in this Privacy Policy. These service providers are required by contract or law to only use or disclose the information as necessary to perform services on our behalf or as otherwise required by law. Although GBA Holding requires these third parties meet our privacy and security requirements, GBA Holding does not control the privacy or security policies of such third parties.
  • With data analytics providers. GBA Holding may share data and personal information with analytics service providers such as the Google and LinkedIn products discussed in this Privacy Policy.
  • With our affiliated companies. GBA Holding may transfer the data and personal information that we collect to other GBA Holding companies, subsidiaries, and related affiliates acting on our behalf for the purposes described in this Privacy Policy.
  • For a merger, acquisition, change in ownership, or reorganization. Data and personal information we have collected may be disclosed to a third party in the event of a merger, transfer of ownership or assets, bankruptcy, or other corporate reorganization.
  • When we are legally permitted or required to do so. GBA Holding may disclose without your prior consent any data or personal information about you or your use of our website and services, if we believe disclosure is necessary.

5. Data Transfer

If you use our services, you are transferring your information to GBA Holding in the United States and Germany. By using the GBA services or providing your information to GBA Holding through the services you consent to the transfer of your personal information to the United States, and GBA Holding handling of your information in accordance with applicable U.S. requirements and this Policy. Accordingly, your personal information may be accessible to courts, law enforcement and national authorities in the United States. You can obtain information about GBA Holding’s policies and practices with respect to service providers (including affiliates) outside the country where you reside, or ask questions about the collection, use, disclosure or storage of personal information by such service providers, by contacting our Privacy Policy Administrator at datenschutz@gba-group.de

6. Privacy Rights

Certain U.S. state and Canada laws, including the California Privacy Rights Act (“CPRA”) and the Personal Information Protection and Electronic Documents Act (“PIPEDA”) grant you rights to control your personal information. Consistent with these laws, GBA Holding gives you options to access, edit, or remove certain information, as well as choices about how we contact you. Although some of these rights apply generally, certain rights will only apply to limited individuals or circumstances.

  • Right to Know and Access Information. You have the right to know about our information collection and sharing practices. You also have the right to access the categories of data we collect, with whom we share or sell that information, and, in some cases, what specific personal information we associate with you or your account. Note that much of the information you are entitled to know or access is disclosed in this Privacy Policy.
  • Right to Data Portability. If you request a copy of your specific information then we will provide it in an easily accessible format.
  • Right to Deletion or Erasure. You may request that we delete the personal information we have collected about you. Depending on the applicable law, in some cases we are required or permitted to retain your information, even if you validly requested we delete or erase it.
  • Right to Correct Information. You may request we correct or rectify inaccurate information we have collected about you.
  • Right to Limit Use of Information for Advertising. You may opt-out of our use of your personal information for advertising purposes.
  • Right to Opt Out. You may opt out of the sale or sharing of your personal information, or automated decision-making. GBA Holding does not currently participate in the sale of data or automatic decision-making.
  • Right to Opt In. You may have the right to opt in to the sharing of sensitive information or data.
  • Right to Withdraw Consent. You may withdraw your consent to our data privacy practices.
  • Right to Non-Discrimination. You have the right to not experience discrimination from us for exercising the rights listed in this section. What we mean by discrimination is denying you access to our services or limiting the quality of our services. However, limiting use of, or deleting, your personal information may restrict the purposes or uses that rely on that information. If you need further assistance, you can contact GBA Holding through one of the channels listed below.
  • We may offer you certain financial incentives permitted by applicable law that can result in different prices, rates, or quality levels. Any legal financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
  • Right to Lodge Complaints. You may lodge a complaint about our use of personal information with a relevant data protection authority.
  • You may file a complaint with the Office of the Privacy Commissioner of Canada. Depending upon the province where you live, you may also (or instead) have the right to file a complaint with the applicable provincial privacy commissioner/regulator.

7. State Specific Rights

California’s “Shine The Light” law permits individuals who are residents of California to annually request a list of their personal information (if any) that GBA Holding disclosed to third parties for direct marketing purposes in the preceding calendar year, and the names and addresses of those third parties. At this time, GBA Holding currently does not share any personal information with third parties for direct marketing purposes.

8. Exercising Your Privacy Rights

To exercise any of your privacy rights, either:

Please include your email address, full name, and your specific information about your request(s) and, if applicable, specifically what information you do not want to receive. If you would like to update or correct your email address, street address or other personal information with us, please include specific details about the information you wish to have updated or corrected.

For requests submitted by form or email, you must provide enough information that allows us to verify your identity. Only you, or your authorized agent may make requests regarding your personal information. An authorized agent must have documentation that they are authorized to act on your behalf. GBA Holding will attempt to fulfill or reject your request within the amount of time required by law.

9. Your Privacy Choices

Messaging and newsletter communications. You may control how you receive certain types of communications by unsubscribing within the body of the communication. Note that some messages are required, service-related messages like transaction confirmation messages, legal policies, or updates.

Cookies and web tracking technologies. You may limit the automatic collection of information by Google, including the collection of personal information about your online activities over time and across third-party websites or online services, by opting-out of such collection. If you want to deactivate Google Analytics, you can download and install the add-on for the web browser used. The add-on for deactivating Google Analytics is compatible with the current versions of Chrome, Internet Explorer, Safari, Firefox and Opera. For the add-on to work it must be loaded and run correctly in the browser. In Internet Explorer, third-party cookies must also be activated. You can find more detailed information at https://tools.google.com/dlpage/gaoptout?hl=de.

You can generally prevent cookies from being stored on your hard disk by selecting "do not accept cookies" in your browser settings. However, this can result in a functional limitation of our offers. You can object to the use of third-party cookies for advertising purposes by opting out using this website (https://optout.aboutads.info).

You can generally opt out of third-party advertisements by installing the plug-in provided by Google at the following link: https://www.google.com/settings/ads/plugin.

If you choose any of these options, you may not be able to use the full scope of functionality of our services.

10. International Users

This is a U.S. website and Service targeted to users in the U.S. and Canada. The GBA Holding US website and services are subject to U.S. and Canadian laws, as applicable, including, without limitation, those governing the privacy and security of your information.

11. Third Party Websites

Our website may contain links to websites of other providers. We have no influence on whether these providers adhere to the data protection regulations. After you click the link, GBA Holding no longer has any influence over the collection, storage, use or processing of any personal information transmitted by clicking the link (such as the IP address or URL of the page that contains the link), as the behavior of third parties is, by nature, beyond GBA Holding’s control. Therefore, GBA Holding is not responsible for the collection, storage, use, disclosure or other processing of personal information by such third parties. For further clarity, this Privacy Policy does not apply to any such third party websites or services; please refer to the privacy statements or policies for such third party websites or services for information about how they collect, use, disclose and protect personal information.

12. Security

GBA Holding takes reasonable steps to secure your data and personal information. We maintain physical, electronic and procedural safeguards to ensure that personal information is stored and processed responsibly. For this reason, all data between your browser and our server is transmitted encrypted via a secure SSL connection. However, no internet transmission is fully secure and we cannot guarantee that information transmitted will remain confidential at all times.

13. Age Restrictions

GBA Holding takes children’s privacy seriously. By accepting the Privacy Policy through your use of our website or services, you certify that you are at least 18 years of age or are at least 13 years of age and are using the services under the supervision of a parent or legal guardian who has agreed to be bound by this Privacy Policy on your behalf. If you are under the age of 13, you are not permitted to use our services.

GBA Holding does not have actual knowledge of any personal information about individuals under the age of 13 whose information has been collected through our website or services. If we become aware that a person submitting information to us is a minor, we delete the information as soon as we discover it and do not use it for any purpose nor disclose it to third parties.

GBA Holding does not knowingly allow visitors under the age of 16 to participate in any promotions or contests made available on the GBA US website from time to time.

14. Changes to Privacy Policy

We may update or change this Privacy Policy from time to time. We will post the changes on our website and will indicate the effective date. Your continued use of services after the changes are effective constitutes your acceptance of the Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy, contact us at:

Corporate Headquarters
GBA Holding GmbH
Goldtschmidtstraße 5
21073 Hamburg
Email: datenschutz@gba-group.de

Site in US:
GBA Clinical Trial Supply U.S. LLC
115 Flanders Road
Westborough
MA 01581
United States of America
service@gba-pharma.com

GBA Central Lab Services U.S. LLC
115 Flanders Road
Westborough
MA 01581
United States of America
service@gba-pharma.com

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